As a local Wiradjuri Man of the Lithgow area, I strongly object to the proposed Lake Lyell Pumped Hydro Energy Storage Project due to its significant, irreversible, and inadequately mitigated environmental impacts. While the transition to renewable energy is essential, it must not come at the cost of irreplaceable ecosystems, threatened species, and long-established Wiradjuri biodiversity values—particularly where less destructive alternatives may exist.
A central concern is the clearing of approximately 102 hectares of native vegetation, much of which holds a high vegetation integrity score. This indicates that the affected bushland is not only extensive but also ecologically valuable, supporting complex habitat structures that have developed over centuries. The proposed clearing includes ancient trees, some estimated to be over 200 years old. These are not simply individual plants but keystone habitat features that cannot be replaced within any meaningful human timeframe. Their loss represents a permanent degradation of the local Wiradjuri Country ecosystem.
The project is expected to remove approximately 800 hollow-bearing trees. These trees are critical habitat for a range of threatened fauna species that depend on tree hollows for nesting, breeding, and shelter. Of particular concern are species such as the Gang-gang Cockatoo and my personal Totem - Glossy Black-Cockatoo, both of which are already under pressure from habitat loss across their range. Tree hollows take decades—often more than a century—to form, meaning that any offset planting or artificial structures cannot replicate their ecological function in the short to medium term.
Further, the proposal poses serious and potentially irreversible impacts to several highly vulnerable species, including the Sooty Owl, Large Bent-wing Bat, Swift Parrot, and Regent Honeyeater. These species are already facing steep population declines, and additional habitat destruction and disturbance could exacerbate their risk of extinction. The cumulative impact of vegetation clearing, increased human activity, noise, and habitat fragmentation must be fully acknowledged as a critical threat to this scared part of Wiradjuri Country.
The biodiversity offset strategy associated with this project is also deeply concerning. While offsets are intended to compensate for ecological loss, they are often implemented in locations far removed from the impact site. In this case, there is a strong likelihood that offsets will not occur within the immediate Lithgow area. This undermines the ecological integrity of the local landscape and results in a net loss of biodiversity for Wiradjuri County and far wider region. Offsets cannot replace the unique environmental conditions, species assemblages, and ecological history of the impacted site, particularly when ancient ecosystems are involved.
Critically, the EPBC Act requires a precautionary approach where there is a risk of serious or irreversible environmental damage. In this case, the evidence clearly indicates that the project is likely to have a significant impact on multiple listed threatened species and their habitat. Avoidance—not merely mitigation—should be the priority. The irreversible nature of habitat destruction, particularly for species dependent on long-established ecological features, cannot be adequately compensated.
In addition to direct habitat loss, the project is expected to cause the interruption of animal movement corridors and degradation of water quality and waterway health including Platypus habitat. The fragmentation of habitat corridors can isolate wildlife populations, reduce genetic diversity, and limit access to food and breeding areas. This is particularly harmful in already stressed ecosystems. Impacts on water quality—through sedimentation, pollution, or altered hydrology—pose further risks to both aquatic and terrestrial species, as well as downstream ecosystems.
These issues should be transparently disclosed and rigorously assessed before any approval is considered. A lack of clarity on key environmental risks raises serious concerns about the adequacy of the project’s environmental assessment.
In summary, the Lake Lyell Pumped Hydro Energy Storage Project presents unacceptable environmental trade-offs. The scale of vegetation clearing, the destruction of irreplaceable habitat, the threat to endangered species, and the inadequacy of proposed Lithgow based biodiversity offsets collectively outweigh the project’s potential benefits. Sustainable energy development must not come at the expense of ecological destruction, particularly where it affects ancient landscapes and already threatened wildlife.
As a Wiradjuri man of this area, I know first hand the impact of centuries of destruction to Country in this area. It is important we all play our part in preserving ancient natural spaces for future generations to experience what little spaces we have left. This destruction contributes to the loss of culture and ancient story specific to this part of Australia. I am deeply concerned for the integrity of Energy Australia Reconciliation Plan based on the allowance of this type of destruction directly in opposition to the core meaning of a Reconciliation Action Plan.
I urge decision-makers to reject this proposal or, at minimum, require substantial redesign to avoid and minimise environmental harm, ensure localised and meaningful biodiversity offsets, and fully protect the ecological and ancient Wiradjuri values of the Lithgow region.
Mandaang guwu.
Thank you.

I object to the project due to:

1. significant environmental damage to existing Lake Lyell which is a critical tourist attraction and recreational centre for the local community. Lake Lyell will become tidal and this will severely impact the recreational and tourist benefits of the lake. Local tourism related businesses will experience e severe economic damage.

2. Significant environmental damage and cultural heritage damage to Mt Walker which is highly important cultural and sacred spiritual site for local Wiradjuri aboriginal people.

3. Very limited or likely negative impact on employment for the people in the Lithgow region - more jobs will be lost due to destruction of tourism infrastructure than gained by this project.

4. Horrendous damage to the visual amenity in the Lithgow and lake Lyell areas - the dam will be usable from main st in Lithgow as an ugly monstrosity if no community benefit.

5 local infrastructure impact - local roads will be highly damaged by this project and the logos region will experience unacceptable disruption including construction noise and pollution of the nearby forested area and the water of lake Lyell.

6. Pumped hydro is outdated technology - other forms of energy storage are the future for australia especially batteries and other technologies. Pumped hydro is extremely damaging to the environment and local communities. It is expensive and inefficient.

8
Batteries vs pumped hydro – a place for both? | Entura
Alternatives to pumped hydro that offer superior flexibility, faster deployment, or lower geographical constraints include utility-scale Lithium-ion batteries (for short-term, fast response), Green Hydrogen (for long-term storage), and Concentrated Solar Power (CSP) with thermal storage. These technologies excel in areas where geography, high construction costs, or water availability limit pumped hydro development.
ScienceDirect.com
ScienceDirect.com
+4
Key Alternatives and Their Advantages
* Lithium-ion Batteries (BESS): Currently superior for fast-frequency response and grid stabilization, with deployment times in months rather than years. Battery energy density is expected to double, making them strong competitors for total storage capacity.
* Green Hydrogen: Offers superior long-duration storage and seasonal flexibility by converting excess electricity into hydrogen for later use in fuel cells or turbines.
Concentrated Solar Power (CSP): Provides stored thermal energy, allowing for dispatchable power after sunset.
Advanced/Closed-Loop Systems: Technologies using high-density solids or waterless slurries reduce the environmental footprint and geographic limitations of traditional large-reservoir pumped hydro.

Comparison to Pumped Hydro:

* Flexibility & Speed: Batteries respond to grid needs in milliseconds.
* Lifespan & Cost: Pumped hydro assets can last over 100 years, making them often cheaper for 8–24 hour storage compared to batteries, which require replacement after 15–20 years.
* Environmental Impact: While batteries require chemical mining, they can be integrated into existing built environments without altering natural landscapes, unlike massive pumped hydro projects.

7. Concerns over Net Energy Loss: the project consumes more energy to pump water than it produces, or reliance on coal for pumping.

Submission Against the Proposed Lake Lyell Pumped Hydro Project

By Frances Chung

To: The Honourable Paul Scully, Minister for Planning and the NSW Department of Planning, Housing and Infrastructure

25th April 2026

Dear Minister

I object to the proposed Lake Lyell Pumped Hydro project primarily on environmental grounds. While I strongly support renewable energy and the transition to lower-emission energy systems, I believe these projects must be undertaken in a way that delivers an overall environmental benefit, rather than simply producing energy at the expense of significant ecological destruction.

The proposed project location at Mount Walker and Lake Lyell is an exceptionally valuable natural area situated very close to established communities. It is not an isolated industrial landscape. It is a highly visible and environmentally significant part of the Seven Valleys region that contains important native habitat and wildlife corridors.

The Environmental Impact Statement acknowledges that approximately 130 hectares of vegetation would be cleared as part of the project. This is an enormous area of habitat destruction, particularly in a landscape already under pressure from past clearing, bushfire and ongoing human activity.

Importantly, this area supports a wide range of native wildlife including:

• Platypus
• Koalas
• Gang-gang Cockatoos
• Glossy Black-Cockatoos
• White-bellied Sea Eagles
• Powerful Owls
as well as many other species dependent on mature forest systems and waterways.

Particular concern should be given to the platypus population within the Lake Lyell and associated water systems. Although platypus is not currently classified as threatened or endangered in NSW, they remain an iconic native species whose populations are increasingly vulnerable to habitat disturbance, water quality changes, riverbank disruption and broader ecological decline. Their presence forms part of the wider environmental value of this landscape. The loss or degradation of habitat affecting species such as platypus should not simply be dismissed because they are not formally listed as threatened. Their existence contributes to the overall ecological integrity of the area.

The EIS also notes the loss of large numbers of mature trees and tree hollows. These hollows are critically important breeding and shelter sites for birds, mammals and arboreal species. Once destroyed, such habitat cannot simply be recreated in the short or medium term. Many hollows may take well over a century to naturally form.

A major concern is the apparent assumption that environmental impacts can be adequately offset by replanting trees after construction. Nature does not operate as a simple collection of replaceable trees. Ecological systems are extraordinarily complex and interconnected that can only develop over very long periods of time.

A newly planted area is not an ecological replacement for a mature functioning ecosystem. Even if revegetation efforts are successful, it would take decades at minimum, and more realistically generations, before any replacement habitat could begin to approach the ecological value currently present on Mount Walker and around Lake Lyell. In many respects, the existing environmental values can never truly be replaced.

This project also represents industrialisation of one of the most scenic and peaceful parts of the Lithgow region. Mount Walker and Lake Lyell are widely valued for their natural beauty, tranquility and environmental significance. Introducing major excavation, vegetation clearing, transmission infrastructure, heavy construction activity and permanent industrial structures into this landscape would fundamentally alter the character of the area.

In my view, this is the wrong project in the wrong location.

Renewable energy infrastructure should not automatically be considered environmentally acceptable simply because it produces renewable electricity. The full environmental cost must be considered and sensible decisions made on the best options. In this case, the ecological destruction, habitat fragmentation, landscape impacts and long-term environmental risks are too significant to justify the proposal when clearly other better alternatives exist.

For these reasons, I strongly object to the proposed Lake Lyell Pumped Hydro project and request that the project not be approved.

To the NSW Department of Planning, Housing and Infrastructure,

I am writing to object to the Lake Lyell Pumped Hydro Energy Storage Project, SSI-77018220.

I support the transition to renewable energy and understand the need for energy storage. However, I do not believe this project has shown that its local environmental impacts would be acceptable, particularly for Lake Lyell, Farmers Creek, and platypus known from the area.

My concern is that the project would use Lake Lyell as part of an active pumped hydro system, rather than leaving it as a relatively stable waterbody. Even if the lake is artificial, it now has ecological and community value. The fact that Lake Lyell was originally created as a dam does not mean it should be treated only as infrastructure.

Platypus are a major concern for me. The project’s own public material identifies risks to platypus, including potential loss of burrowing and feeding habitat, changes to movement and behaviour, and increased predation and entrapment risks. It also acknowledges a lack of data and research into platypus in a dynamic water environment such as this project.

I am concerned that the project would involve repeated changes to Lake Lyell’s water level, with the EIS summary describing fluctuations of approximately 2.5 metres. For a waterway and lake edge used by platypus, I do not think that risk should be treated as minor or easily managed.

I am also concerned that some of the project’s environmental risk appears to be left to future management, monitoring, and mitigation plans. Monitoring a problem after approval is not the same as avoiding the problem in the first place. If local platypus are harmed or displaced, that impact may not be easy to reverse.

I also think the assessment should give more weight to whether other energy storage options could meet the same need with less direct impact on aquatic habitat. Other technologies have their own impacts, but alternatives should be properly considered where they may avoid altering a lake and creek system in this way.

This is not an objection to renewable energy storage in principle. It is an objection to this project in this location. The energy transition should not come at the cost of avoidable damage to local waterways, native species, and places that already hold ecological and community value.

On the information available to me, I do not believe the project has demonstrated that its impacts on Lake Lyell, Farmers Creek, and platypus habitat can be avoided or adequately managed.

I therefore object to the Lake Lyell Pumped Hydro Energy Storage Project.

Yours sincerely,

Name withheld

I am writing to formally object to the proposed Lake Lyell Pumped Hydro project and to outline the very real and personal impacts this project would have on my family, my home, and my way of life.
I live at 285 Sir Thomas Mitchell Drive, South Bowenfels, approximately 200 metres from the Lake Lyell access area. My family and I have lived here for 33 years. This is not just a property to us - it is our home. We raised our children here, and we chose this location specifically for the peace, quiet, safety and natural environment. We intended to remain here for the rest of our lives.

Lake Lyell is central to our lifestyle and to the wider community. People travel long distances to experience the calm, scenic and peaceful environment that the lake provides. If this project proceeds, that experince will no longer exist, not just during construction, but permantly.
The existing tourism at Lake Lyell already supports the local economy in a sustainable way. In contrast, the prosed project will destroy the qualities that attract visitors in the first place. Any short-term construction employment does not compensate for the long-term damage to tourism, amenity and community wellbeing.

One of my greatest concerns is the impact of construction traffic. Sir Thomas Mitchell Drive is the only access road to the proposed site. There is no alternative route. This means every construction vehicle, every heavy truck, and every piece of machinery will pass directly by my home.
According to the proponent's own figures, this road will carry approximatelt 1,200 vehicle movements per day, including around 300 heavy vehicle movements daily. These are not minor increases, they represent a complete transformation of a quiet rural-residental road into an industrial haul route.
As a resident, this has serious implications for my daily life. Simple, everyday activities such as entering or exiting my driveway, walking near the road, or having visitors safely access my home will become stressful and potentially dangerous. The constant movement of heavy vehicles will bring noise, vibration, dust and exhaust pollution, extending from early morning through to evening, day after day, for years.
Sir Thomas Mitchell Drive is one of the oldest roads in the distict, never designed to carry sustained heavy industrial traffic. Increased traffic volumes and truck weights raise very real concerns about road safety, accidents, road degradation, and emergency access. Living on the only access road means I will have no way to avoid these impacts, they will be unavoidable and inescapable.

Beyond traffic, the project will subject residents to years of blasting, dust and construction noise. This will make normal life extremely difficult and will create ongoing stress and anxiety. There are also legitimate concerns about vibration damage to homes and the cumulative toll of living next to an active construction zone for an extended period.
No mitigation plan can change the fact thar this environment will be unliveable for residents like me during construction.

The area around Lake Lyell supports native wildlife that relies on specific habitats. Animals cannot simply be relocated at will. Promises to "manage" wildlife do not reflect ecological reality. We have already lost too much native fauna over time, and this project risks causing permanent and irreversible environmental harm.

Finally, I ask what happens when this project is no longer viable or useful. The community will be left to deal with the long-term consequences - altered landscapes, damaged amenity, and a lake that may never return it what it once was. Meanwhile, those who promoted the project will have moved on.

This project will destroy the lifestyle my family has built over more than three decades. It will permanently alter the character of Lake Lyell, create serious risks through industrial-scale traffic on the only access road, damage wildlife, and undermine a sustainable tourism economy.
These impacts cannot be meaningfully mitigated. They will be experienced every day by residents like me.
For these reasons, I strongly object to the Lake Lyell Pumped Hydro project and request that it not proceed.

Objection to Climate Change Risk Assessment (CCRA)
Lake Lyell Pumped Hydro Energy Storage Project (SSI-77018220)
This submission strongly objects to the Climate Change Risk Assessment (CCRA) as a flawed, internally biased, and non-conservative basis for approving long-lived energy infrastructure. The assessment presents an appearance of technical rigour while systematically understating real-world uncertainty, extreme event risk, and long-term system vulnerability.
1. Risk Framework is Pre-Loaded Toward “Acceptability”
The CCRA uses a standard likelihood–consequence matrix under AS 5334, but the entire structure is predisposed to produce “low” or “medium” outcomes.
Key issue:
Risk is defined only in terms of project manageability, not system failure tolerance
“Residual risk” is treated as acceptable by default unless it becomes extreme
The framework does not include a “do not proceed” threshold
This is not a neutral risk assessment—it is a project validation tool wrapped in risk language.
2. Developer-Led Workshop Bias Compromises Independence
The core risk identification was conducted via a workshop involving:
EnergyAustralia
consultants engaged by the proponent
There is no evidence of:
independent hazard validation
external climate risk adjudication
counter-expert challenge to assumptions
This creates a structural conflict:
the same project proponents defining, rating, and then “mitigating” their own risks
That is not robust risk governance—it is procedural self-assessment.
3. Overreliance on Climate Model Scenarios Masks Real Uncertainty
The assessment depends heavily on:
NARCliM 2.0 downscaled projections
IPCC-aligned emissions scenarios (SSP1-2.6 / SSP3-7.0)
ensemble averages presented as planning inputs
But these are not engineering certainties—they are long-range scenario constructs with compounding uncertainty.
Critical flaw:
rainfall, flood behaviour, and storm systems (the most infrastructure-relevant risks) are explicitly low confidence
yet operational conclusions are still downgraded to “low residual risk”
This is a false precision problem: uncertain inputs converted into confident design assurances.
4. Extreme Events Are Systematically Underweighted
The assessment acknowledges:
bushfire risk
flooding risk
storm and lightning impacts
However:
these are treated as isolated delay risks, not cascading system failures
compounding events (fire + flood + access failure + grid disruption) are not meaningfully analysed
construction risks are simplified to “delay impacts”
From a conservative engineering standpoint, this is a critical failure:
infrastructure resilience is not tested against worst-case compound events
5. “Low Residual Risk” Conclusion Is Not Justified
The final conclusion that all operational risks are “low” is not supported by the underlying uncertainty.
This conclusion rests on:
assumed effectiveness of mitigation measures
assumed compliance with standards
assumed operational control under future climate conditions
But none of these assumptions are stress-tested under:
prolonged extreme heat
multi-day fire events
extreme rainfall clustering
infrastructure interdependency failure
In effect:
“low risk” is an administrative classification, not a demonstrated physical certainty.
6. Adaptation Measures Are Treated as Proof of Safety
The report lists standard controls:
fire-resistant design
drainage and flood forecasting
vegetation management
emergency response planning
However, these are baseline expectations for any major infrastructure, not evidence of climate resilience.
The key flaw is logical:
presence of mitigation measures is treated as proof that climate risk is resolved
This is circular reasoning, not validation.
7. Time Horizon Mismatch Undermines the Entire Assessment
The project lifespan is 80–100 years, yet:
meaningful confidence in climate projections is limited to mid-century horizons
uncertainty increases non-linearly beyond 2050–2070
Despite this, the assessment concludes:
no additional measures are required for a century-scale asset
This is not conservative engineering—it is long-term extrapolation based on short-to-medium term model agreement.
8. Absence of Energy-System Risk Context
The CCRA evaluates only:
direct physical impacts on the project
It does not evaluate:
grid reliability under extreme weather stress
dependence on transmission stability
system-wide vulnerability under high renewable penetration scenarios
comparative resilience of dispatchable baseload alternatives (coal or nuclear)
This creates a narrow framing bias where:
only project survival is assessed, not system contribution under stress conditions
Conclusion
The Climate Change Risk Assessment is structurally biased toward approval through:
scenario-driven modelling treated as predictive certainty
developer-led risk definition without independent challenge
systematic underweighting of extreme and compound events
overconfidence in mitigation effectiveness
and a default conversion of uncertainty into “low residual risk”
It does not provide a robust engineering basis for approving irreversible, century-scale infrastructure.
At minimum, the assessment fails to demonstrate that the project is resilient under realistic worst-case climate conditions and therefore should not be relied upon as justification for approval in its current form.
Short recap
Risk framework is approval-biased, not decision-neutral
Climate models are treated as precise when they are uncertain scenarios
Extreme and compound events are under-assessed
“Low residual risk” is not independently justified
Mitigation measures are assumed effective, not proven
Long-term infrastructure horizon is mismatched with climate certainty

Submission of Objection – Lake Lyell Pumped Hydro Energy Storage Project (SSI-77018220)
Social Impact Assessment Critique
This submission strongly objects to the adequacy and conclusions of the Social Impact Assessment (SIA) for the proposed Lake Lyell Pumped Hydro Energy Storage Project.
The assessment does not provide a credible or sufficiently independent basis for concluding that the project’s social impacts are acceptable. Instead, it relies on constrained consultation, optimistic mitigation assumptions, and a risk classification framework that systematically understates long-term and irreversible community harm.
1. Absence of Genuine Social Licence
The SIA acknowledges concerns across tourism operators, residents, Aboriginal stakeholders, and recreational users, yet treats these concerns as inputs rather than determinants.
The consultation base is extremely limited relative to the scale and duration of impact:
34 interviews and 34 recreational surveys cannot reasonably represent a region-wide transformation affecting multiple communities over 80–90 years.
The result is a procedural exercise in consultation rather than evidence of community consent or social licence.
2. Systematic Underweighting of Irreversible Impacts
The project involves permanent transformation of a lake-based recreational and ecological system into industrial energy infrastructure.
However, the SIA consistently reframes permanent change as:
“manageable”
“mitigatable”
“residual impact”
This approach fails to distinguish between:
temporary construction disturbance, and
irreversible landscape, ecological, and amenity change
From a planning perspective, this represents a fundamental assessment weakness: mitigation cannot restore lost environmental or social values once industrialisation occurs.
3. “Residual Impact” Framework Masks Severity
The use of residual risk categories (low/medium/high) gives the appearance of objectivity but is highly sensitive to underlying assumptions about mitigation effectiveness.
Critically:
“High residual impact” findings do not prevent approval
Mitigation effectiveness is assumed rather than demonstrated
Long-term uncertainty is deferred to future “adaptive management”
This creates a structural bias where even significant harm is reclassified as acceptable through procedural framing.
4. Inadequate Treatment of Tourism and Amenity Loss
The Lithgow region includes established recreation and tourism assets dependent on natural amenity, including Lake Lyell’s current recreational use.
The SIA does not adequately assess:
cumulative loss of regional tourism identity
displacement of high-value amenity-based businesses
long-term reputational change to the landscape
These impacts are treated as secondary and localised, despite being central to the existing regional economy.
The likely outcome is not temporary disruption, but permanent devaluation of the area’s tourism and recreational function.
5. Social Impacts Are Recast as Transition Effects
The SIA links social vulnerability to broader regional transition (including coal sector decline). This framing risks attributing community impacts to macroeconomic change rather than project-specific decisions.
This dilutes accountability by:
shifting causality away from the project footprint
normalising disruption as “inevitable transition”
A planning assessment must isolate project impacts, not embed them within broader policy narratives.
6. Construction Impacts and Workforce Accommodation Understated
The proposal for a temporary workforce of up to 500 people introduces significant localised pressure on:
housing availability
traffic and road safety
community services and infrastructure capacity
These impacts are treated as temporary and manageable, despite likely multi-year duration and concentrated spatial effects on Lithgow and surrounding rural communities.
7. Cultural and Environmental Values Insufficiently Integrated
The SIA acknowledges Aboriginal cultural significance and environmental values but does not demonstrate how these are weighted in decision-making relative to engineering and economic objectives.
There is insufficient evidence that:
cultural heritage impacts are determinative rather than advisory
ecological and recreational values are treated as constraints rather than trade-offs
This creates a perception that social and cultural values are secondary to project delivery.
8. Overall Assessment Integrity Concerns
The SIA functions primarily as a project justification document rather than an independent impact evaluation.
Key concerns include:
reliance on developer-led assumptions
optimistic mitigation effectiveness
weak treatment of irreversible change
limited consultation base relative to scale of impact
approval-compatible risk classification structure
As a result, the assessment does not provide a sufficiently robust basis for concluding that the project’s social impacts are acceptable.
Conclusion
The Social Impact Assessment does not adequately demonstrate that the Lake Lyell Pumped Hydro Energy Storage Project will avoid, minimise, or appropriately compensate for significant long-term social harm.
The project represents a major and permanent transformation of a valued recreational, ecological, and community landscape, with impacts that are under-assessed and structurally normalised through the assessment framework.
For these reasons, the project should not be approved.
Prioritise FAR SUPERIOR Australian Coal instead.

Objection to Lake Lyell Pumped Hydro Energy Storage (SSI-77018220)

We submit this objection on behalf of our concerned community group in relation to the Lake Lyell Pumped Hydro Energy Storage proposal.

Our position is based on detailed review of the exhibited material, local knowledge of the area, and long-standing concerns about cumulative environmental, social, and economic impacts.
We consider the project, as currently designed and justified, to be fundamentally flawed in both its assumptions and its impacts.

1. Absence of genuine social licence in the Lithgow region
There is no credible social licence for this project in its current form.
Community opposition is not limited to isolated objections but reflects a broad and consistent rejection of the proposal across residents, tourism operators, and environmental stakeholders.
The consultation process has been procedural rather than genuinely responsive.
Key concerns raised by the community—loss of amenity, industrialisation of a recreational lake, noise, traffic, and long-term environmental change—have not been meaningfully resolved.
A project of this magnitude should not proceed on the basis of administrative approval alone when the affected community remains fundamentally opposed.

2. Permanent transformation of a natural and recreational landscape
Lake Lyell is not an industrial site—it is a valued recreational and ecological landscape.
The proposed works will permanently alter its character through:
large-scale excavation and tunnelling
creation of an upper reservoir and associated dam infrastructure
introduction of continuous industrial activity into a quiet regional setting
The result is not “temporary construction impact” but permanent industrialisation of a natural water system that supports tourism, recreation, and biodiversity.

3. Ecological impacts underestimated and normalised
The EIS significantly underrepresents the seriousness of ecological disruption, including:
clearing and fragmentation of over 100 hectares of native vegetation
loss of mature hollow-bearing trees essential for wildlife habitat
disruption to species such as platypus, cockatoos, and koalas
long-term alteration of aquatic habitat conditions in Lake Lyell and Farmers Creek
These impacts are presented as manageable, but in reality they represent irreversible structural change to local ecosystems.

4. Hydrological stress and “washing machine” effects ignored in full context
The daily cycling of large water volumes between reservoirs introduces ongoing hydrological stress, including:
sediment resuspension and turbidity increases
thermal and oxygen stratification changes
long-term degradation of water quality stability
cumulative ecological disruption rather than isolated events
These effects are not temporary—they repeat daily across decades of operation. The EIS does not adequately model the long-term ecological fatigue this system will generate.

5. Greenhouse gas assessment is incomplete and overly narrow
The greenhouse gas accounting framework is heavily constrained by standard reporting categories that do not reflect the full system impact of the project.
Key concerns include:
reliance on Scope 2 assumptions tied to projected future grid decarbonisation
limited visibility of full lifecycle Scope 3 emissions from enabling infrastructure
insufficient treatment of long-lived greenhouse gases in electricity transmission systems
Critical gap: SF₆ and high-voltage infrastructure
The assessment includes sulfur hexafluoride (SF₆) only as a minor leakage source, despite its extreme climate potency and long atmospheric lifetime.
However, it does not adequately account for:
the total SF₆ inventory across substations, switchgear, and grid connection infrastructure
cumulative leakage over decades of expanded grid operations
emissions embedded in system-wide transmission upgrades required to support intermittent generation and storage
This results in a structurally incomplete climate impact assessment that underrepresents long-term forcing agents.

6. Transmission expansion and regional industrialisation impacts
The project cannot be assessed in isolation from the transmission infrastructure required to support it.
This includes:
new or upgraded high-voltage transmission corridors
substations and switching facilities
construction corridors, access roads, and staging areas
These components collectively contribute to a broader pattern of regional industrialisation that permanently alters landscape character, visual amenity, and ecological continuity.
The cumulative impact of this infrastructure is not adequately integrated into the project justification.

7. Economic risk and long-term liability exposure
Large pumped hydro projects internationally have consistently demonstrated:
cost escalation beyond initial estimates
schedule delays and construction complexity risks
long-term maintenance burdens for underground and hydraulic systems
These risks are not fully transparent in the benefit case presented.
Public exposure increases over time while local benefits remain limited or indirect.

8. Questionable net benefit framing and system assumptions
The project is justified on the basis of supporting ‘renewable’ energy integration and improving system reliability.
However, this framing assumes:
continued expansion of variable generation requiring large-scale storage
stable long-term performance of complex hydrological infrastructure
predictable energy market conditions over multi-decade horizons
These assumptions are flawed and do not account for far superior alternative system pathways that offer far superior, cheap, reliable, secure, simpler, less intrusive, and more geographically dispersed solutions that actually work on demand such as Australian Coal and future Nuclear Power with minimal environmental footprint - that are not reliant on hostile CCP actors and fraught supply chains.

9. Conclusion
Our community group considers the Lake Lyell Pumped Hydro Energy Storage proposal to be fundamentally misaligned with the environmental, social, economic and security interests of the Lithgow region.
The project, as currently assessed, is characterised by:
inadequate social licence
underestimated ecological and hydrological impacts
incomplete greenhouse gas accounting (particularly SF₆ and infrastructure-related emissions)
significant transmission-driven landscape disruption
elevated economic and delivery risk
insecure control

We submit that the project requires full reassessment with a stronger emphasis on:
cumulative and lifecycle environmental impacts
transparent infrastructure-wide emissions accounting
prioritisation of sovereign energy security and national security
and demonstrable, enduring community consent
Until these issues are resolved, approval would represent an unacceptable level of environmental, social and energy security risk for the region.

I strongly object on the following grounds:->

1. Fundamental lack of social licence
The Lake Lyell Pumped Hydro proposal proceeds in the face of sustained and well-documented local opposition.
This includes concerns from residents, tourism operators, and environmental stakeholders regarding irreversible landscape change, industrialisation of a natural recreational asset, and disruption to local amenity.
Despite this, the project is advanced as State Significant Infrastructure, giving the appearance that procedural approval is being prioritised over genuine community consent.
A project of this magnitude, permanently altering a major regional landscape, does not currently demonstrate a credible social licence to operate.

2. Severe and under-acknowledged ecological impacts
The Environmental Impact Statement understates the scale of ecological disruption associated with:
clearing of over 100 hectares of native vegetation
loss of mature hollow-bearing trees critical for biodiversity
fragmentation of habitat corridors supporting koalas, cockatoos, and other protected species
permanent alteration of aquatic ecosystems in Lake Lyell and Farmers Creek
These impacts are presented as manageable or mitigable, despite representing long-term structural changes to a sensitive ecosystem.
The construction phase alone represents a high-intensity ecological disturbance event, not a temporary impact.

3. Hydrological uncertainty and water quality degradation risk
The pumped hydro operation requires repeated cycling of large volumes of water daily.
This introduces significant risks including:
turbidity increases and sediment resuspension (“washing machine effect”)
thermal stratification disruption
cumulative water quality degradation over time
altered downstream ecological flows in Farmers Creek
These impacts are acknowledged in principle but are not robustly quantified over the full operational lifecycle.

4. Greenhouse gas assessment limitations and system boundary bias
The greenhouse gas assessment is heavily dependent on narrow accounting frameworks that do not reflect full system impacts.
Key deficiencies include:
reliance on Scope 2 emissions assumptions tied to projected grid decarbonisation trajectories
limited treatment of full lifecycle Scope 3 emissions from enabling infrastructure
insufficient integration of long-lived greenhouse gases in electrical infrastructure systems
SF₆ and electrical infrastructure gap
A significant concern is the incomplete treatment of sulfur hexafluoride (SF₆), used in high-voltage switchgear and substations required to integrate and stabilise renewable-heavy grids.
While SF₆ leakage is nominally included, the assessment does not:
quantify total SF₆ inventory across all associated substations and transmission infrastructure
model cumulative leakage over multi-decade infrastructure expansion
account for the extreme atmospheric lifetime of SF₆ (on the order of millennia)
This results in a potential underestimation of long-term climate forcing impacts associated with grid expansion.

5. Transmission infrastructure and landscape industrialisation
The project requires significant supporting infrastructure including:
transmission line augmentation
substations and switching facilities
access roads, tunnelling works, and construction corridors
These elements contribute to cumulative landscape-scale industrialisation, with permanent visual, ecological, and cultural impacts extending beyond the immediate project footprint.
The assessment does not fully integrate the combined impact of these infrastructure layers on regional landscapes.

6. Economic risk and cost escalation concerns
Large-scale pumped hydro projects globally have demonstrated a consistent pattern of cost escalation and schedule delay risk.
Key concerns include:
uncertainty in final delivered cost relative to initial estimates
long-term maintenance liabilities for underground and hydraulic infrastructure
external transmission upgrade costs potentially borne by broader system users
risk of stranded or underutilised infrastructure under changing energy market conditions
These risks are not fully reflected in the public benefit framing of the project.

7. Questionable reliability, security and system efficiency assumptions
The project is justified on the basis of improving grid reliability and storing excess renewable energy.
However:
it increases system dependence on long-distance transmission and centralised infrastructure
it assumes stable and predictable renewable generation expansion trajectories
it introduces additional conversion losses inherent in pumped hydro cycles
The net system efficiency gains are therefore contingent and not guaranteed under all future demand and supply scenarios.

8. Conclusion
The Lake Lyell Pumped Hydro Energy Storage project represents a high-impact infrastructure proposal with substantial unresolved concerns.
These include:
absence of demonstrated social licence
significant ecological and hydrological disruption
incomplete greenhouse gas accounting (particularly SF₆ and enabling infrastructure)
major transmission and landscape impacts
economic cost and delivery risk uncertainty
reliance on optimistic long-term energy system assumptions
lack of sovereignty and national security

On balance, the project requires a far more rigorous reassessment of:
energy security and national security
full lifecycle environmental impacts
cumulative infrastructure emissions and SF₆ system-wide accounting
and genuine community consent prior to approval consideration
At present, the assessment framework does not adequately demonstrate that these impacts are fully understood, transparently quantified, or acceptably mitigated.

Yiradhu marang, yindu Zoe Walsh ninna Wiradjuri migay. Good day, my name is Zoe Walsh and I am a proud Wiradjuri woman.
I am a proud member of this Aboriginal (I am an Aboriginal person, not First Nations or Indigenous) community. I take part in walkabouts, Aboriginal dancing, truth-telling and storytelling sessions with local Traditional Owners and Elders. These local Traditional Owners and their group have not been consulted by the organisations working on this Lake Lyell Pumped Hydro Project (it is written in Energy Australia's documents that they have consulted local Traditional Owners but this is a lie); why would these organisations invite non-local Aboriginal peoples/people who are not local Traditional Owners in to try and identify the site when there are locals who know the truth and are happy to share especially if it will bring something positive to this town.

I morally do not agree with this Pumped Hydro Project at Lake Lyell for the lake is not big enough, it will disrupt/destroy a sacred site (a songline path, wedge tail eagle Dreaming Site and more) and is the tallest mountain in this area. Mount Walker was known to be used as a look out site-pre and post colonisation. Why destroy a local Sacred site? This site does not just hold significant meaning for Aboriginal peoples it is a local go-to recreation site for all. Many people have journeyed to the top seeing the 360 degree views. Heritage and stories are already being lost and misplaced by Energy Australia's (EA) "discovery" (as EA called it on Facebook) of 1344 artefacts from Mt Walker. EA took these pieces to Sydney to be examined and are "now secured in a temporary keeping place". I have attached this post, the captioned post has a big title of "Artefacts returned to Country". They should never have left Lithgow let alone for Aboriginal peoples to find out from Facebook that this has happened. This is all completely distressing as a local Aboriginal person who is not able to access this site and now these artefacts. They do have plans to create a 'Cultural Center' I believe this will also be done with the previously consulted non-local Traditional Owners/Aboriginal peoples producing a Center no one in the community feels welcome/safe/at peace to look at these 1344 artefacts. I know at least one person who has asked for these artefacts to be brought into their class to show the students and not one employee from EA is able to help out this local resident. I also work in a local school, it would be so positive for students to see what is in our backyard. If EA has found 1344 in one area image if they looked at the entire area, how can they destroy a sacred site? Especially for an energy source that will not suffice and is just destroying the area.

Farmers Creek and Lake Lyell have platypus activity. They are a thriving species, with the water levels never affecting their habitats. The Pumped Hydro Project with fluctuating water levels will critically affect many Indigenous animals and recreation activities the lake is known for (fishing, tubing, camping, day trips).

I object to the Pumped Hydro project for the long lasting effects on the local environment here with little benefits and no long term benefits. If our Lake would withstand this project without damage I would support it but it does not and EA has not taken care of the Country on which they tread. Sir Thomas Mitchell Drive is falling away (I have attached a few photos of this), it is not a safe road for the cars that commute daily let alone if there were trucks constantly going back and forth. My street neighbors are all distressed from all the hardship EA is causing. One neighbour has seen Farmers Creek run white after EA had done some drilling, this has not been documented anywhere by Energy Australia (EA). In EA's home visits along this road they have had some people get really emotional from the unknown and what they do know is not positive about this project, the workers from EA have never provided comfort for these people. These are the people that will be directly affected by this project. Our street is known to be full of wildlife, serenity and beauty. If this project goes ahead our street will be filled with sorrow, noise pollution (trucks, drilling, construction), air pollution and disruption. This is not fair to Mother Earth, this Country on which I am sitting writing this, ancestor spirits, stories that are held in this rich soil, fish in Lake Lyell, birds who dwell at Mt Walker, and to the people of Lithgow- Aboriginal and non-Aboriginal peoples.

Yindyamarra is a Wiradjuri Lore word, it means to be respectful, be gentle, be polite, be honorable and do slowly. We ask this of visitors and residents on this part of Country. We should treat all animals, land, water, sky and peoples with Yindyamarra. Energy Australia is disrespecting, dishonouring and ruining this ancestral land by trying to create this Pumped Hydro on Mt Walker.

Please take your time to reflect on the objections to this project. Also, see the truth in the lies that have been published by the people trying to force the go ahead for the Lake Lyell Pumped Hydro Energy Storage project. I am trying to stand up for my culture, our Country and this town.